General Rule: The Supreme Court has recognized students' right to free expression in public schools under the free speech clause of the First Amendment. However, this right is not absolute. 72 Students have a limited right to distribute religious material inside public schools. Student religious expression may be limited if it substantially interferes with or disrupts the school's activities or if it involves coercive proselytizing. Moreover, in order to avoid violating the Establishment Clause, it is essential that the school neither sponsor nor appear to sponsor the distribution of religious material by students. 73 How may a school limit a student's distribution of religious material prepared by outside organizations? A school may limit such distribution of non-school materials by a student as it may limit students' free speech in any circumstance: it may do so as long as the restrictions are reasonably related to legitimate pedagogical concerns (e. g., maintaining order, ensuring a school free from coercive pressure). 74 It is essential that schools take care to neither sponsor nor appear to sponsor the distribution of religious material by students. To this end, the school may require a statement on all religious material disclaiming school endorsement. 75 School authorities may also impose restrictions on school-sponsored expressive activities that students, parents and members of the community might reasonably believe bear the school's imprimatur, such as a student newspaper or hallway bulletin board. 76 What concerns arise when students distribute religious material prepared by outside organizations? The distribution by students of religious material, under a school's auspices and with its apparent sanction, creates the serious danger of school and state advancement of specific religious practices or beliefs, or at a minimum the impression of such endorsement, which may violate the Establishment Clause. Students of minority religions, or those who do not practice a religion, may face considerable pressure from students distributing the religious material to accept it, and may be harassed, intimidated, or ostracized if they decline. Such distribution may interfere with the rights and well-being of other students, as well as disrupt the educational process and the fundamental mission of the school to create a learning environment that is hospitable to all students. May school officials totally prohibit students from distributing religious material that they prepare themselves? The U. S. Supreme Court and Federal courts have not yet resolved this question, which arises less frequently than the issue of distribution of religious material prepared by outside organizations. However, because students also have free speech rights, student distribution of religious material prepared by students may be more difficult to restrict than material prepared by outside groups. However, since a school is a nonpublic forum, it is likely that a school will be able to restrict these materials for pedagogical purposes. Sample Scenario: Fifth-grader Distributes Religious Pamphlet to Peers at Lunchtime Charles Hamilton, a fifth grade student at Benjamin Franklin Elementary School, brought 35 copies of a pamphlet entitled "Good Fun" to school. The pamphlet, prepared by an evangelical organization, contained crossword puzzles, word searches and comic strips. The theme running through "Good Fun" was the power of religion and the evils of secularism. Charles gave out his copies of "Good Fun" during lunch to the students who were waiting in the cafeteria line. Jonathan Freeman, a fourth grade student, accepted the pamphlet and played through the puzzles that evening. When Jonathan's mother realized that the pamphlet was religious material of a proselytizing nature, she called the principal of Benjamin Franklin Elementary School seeking an explanation. The principal had no knowledge that Charles had distributed "Good Fun" and agreed with Mrs. Freeman that the matter had to be looked into and resolved. How should the principal resolve this matter? Does Charles have the right to dis-tribute "Good Fun" in school? The school can allow Charles to distribute "Good Fun" subject to certain time, place, and manner restrictions designed to prevent disruption to the educational process and to prevent disruption of the rights and well-being of fellow students. Such content-neutral regulations typically provide that materials may only be distributed during certain times of the day, and from designated locales.